TECHNICAL MEMORANDUM

REF: DATE: TO:

MAX-2013101.00 December 20, 2013 Mr. Timothy W. Brennan Executive Director Pioneer Valley Planning Commission 60 Congress Street, 1st Floor Springfield, MA 01104 Mr. Jason DeGray, P.E., PTOE Ms. Erica Guidoboni, P.E. Proposed MGM Development, Springfield, MA Regional Traffic Impact Peer Review

FROM:

RE:

Greenman-Pedersen, Inc. (GPI), on behalf of the Pioneer Valley Planning Commission (PVPC) has conducted a peer review of the regional traffic impacts of the proposed MGM Springfield destination resort-style casino development proposal (herein referred to as the Project) in the City of Springfield, Massachusetts. Due to the unique nature and scale of this Project, PVPC in association with GPI is providing these review services on behalf of eight (8) potentially impacted “surrounding communities” in in an effort to provide an independent evaluation of transportation impacts. These communities include the Town of Agawam, City of Chicopee, Town of East Longmeadow, City of Holyoke, Town of Longmeadow, Town of Ludlow, Town of West Springfield, and Town of Wilbraham. As the peer review consultant for the PVPC, our goal is to ensure that the traffic study associated with the Project has been prepared according to industry standards and accurately portrays potential impacts. Our peer review is summarized in this memorandum into the following components. 1. 2. 3. 4. Review Process Trip Generation Trip Distribution Traffic Impact Analysis


Greenman-Pedersen, Inc.
181 BALLARDVALE STREET, SUITE 202, WILMINGTON, MA 01887 TELEPHONE: (978) 570-2999 FACSIMILE: (978) 659-3044 An Equal Opportunity Employer

REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

5. Revitalization Potential 6. Community-Specific Traffic Impacts 7. Look-Back Methodology The scope, methodology and thoroughness of these components as contained within the Traffic, Impact, Access & Parking Study (TIAPS) prepared by The Engineering Corp. (TEC), MGM’s traffic consultant, have been reviewed to ensure overall study adequacy and to evaluate the appropriateness of the proposed mitigating actions. It should be noted that this review also included a significant amount of independent research and analysis to validate the distinctive components of this project. Background The MGM Springfield development proposal is a mixed-use commercial development anchored by a gaming resort-style casino to be located on a series of land parcels bounded by East Columbus Avenue to the west, State Street to the north, Main Street to the east, and Union Street to the south in the South End neighborhood of Springfield, Massachusetts. Figure 1 presents an overview of the Project development area. Specifically the analysis contained within the TIAPS is based on the development program which includes:      501,108 square foot (sf) casino resort (with 3,821 gaming positions) 250 room hotel, 52 residential apartment units, 4,000 sf casino/retail employee daycare facility, 159,397 sf retail and entertainment center known as Armory Square, which includes multiple retail tenants, restaurants, an event plaza, general office space, a radio station, a multi-screen (12 screens) cinema and 15-lane bowling alley.

MGM’s traffic consultant, TEC prepared the TIAPS for the Project which was included as part of the Draft Environmental Impact Report1 (DEIR) submitted to fulfill the requirements of the Massachusetts Environmental Policy Act (MEPA) on December 16, 2013. The TIAPS assesses existing traffic conditions within the study area. This assessment includes an inventory of existing roadway geometry, daily and peak period traffic counts, and a review of the crash history in the area. The study also evaluates the traffic impacts of the proposed project. Specific traffic projections for the Project were established, along with future traffic demands due to projected regional traffic growth, independent of the proposed development. An eleven-year horizon (year 2024) traffic analysis was performed for this study. Finally the study discusses
1 (Energy and Environmental Affairs - EEA #15033)

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Source: http://formandplace.com/visioning/

Figure 1 Development Area Aerial Map

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possible measures to improve existing and future traffic operations in the area, while offsetting the traffic-related impacts associated with MGM Springfield. To facilitate this review process MGM/TEC made portions of this TIAPS available in draft form to GPI prior to the MEPA submission date. Review Process The process by which this regional traffic impact review has been conducted is unique and therefore warrants discussion. The provisions of the Massachusetts Expanded Gaming Act and the timeline under which this review process has been conducted should be understood as it establishes the context in which these abutting communities are operating in understanding the complexities of this significant development project of unique regional impact and consequence. Massachusetts Expanded Gaming Act Signed into law on November 22, 2011, the Massachusetts Expanded Gaming Act establishes the parameters under which gaming licenses will be awarded in the Commonwealth. The act allows for the licensure of up to three (3) destination resort-style casinos, one in each of three geographic regions across the state, along with a single slots parlor facility statewide. Currently MGM Springfield is the only viable proposed destination casino remaining in Region B2. Given the unique nature of this project and the associated licensure process it is important to note the key provisions established in the gaming act pertaining to surrounding communities. As defined in the gaming act surrounding communities are: …municipalities in proximity to a host community which the commission determines experience or are likely to experience impacts from the development or operation of a gaming establishment, including municipalities from which the transportation infrastructure provides ready access to an existing or proposed gaming establishment.

2

Region B consists of Berkshire, Franklin, Hampshire and Hampden Counties. All other proposed casinos in this region failed to pass the host community referendum required to be considered for licensure by the MassGaming Commission. MGM Springfield passed its host community referendum 58% to 42%.

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It is important to note that while the eight communities selected to be the focus of this regional review process either share a common border with the City of Springfield, or are otherwise in close proximity to the City, this does not automatically qualify these communities to receive surrounding community status per the gaming act. Surrounding community status is either preestablished between a casino applicant and a community prior to the Phase II application deadline for destination resort casino licenses of December 31, 2013, or subsequently if a community petition for surrounding community status is granted by the gaming commission. Per the Gaming Act - Section 15 No applicant shall be eligible to receive a gaming license unless the applicant meets the following criteria and clearly states as part of an application that the applicant shall: (7) identify the infrastructure costs of the host and surrounding communities incurred in direct relation to the construction and operation of a gaming establishment and commit to a community mitigation plan for those communities; (9) provide to the commission signed agreements between the surrounding communities and the applicant setting forth the conditions to have a gaming establishment located in proximity to the surrounding communities and documentation of public outreach to those surrounding communities; provided, however, that the agreement shall include a community impact fee for each surrounding community and all stipulations of responsibilities between each surrounding community and the applicant, including stipulations of known impacts from the development and operation of a gaming establishment; Further – Section 18 In determining whether an applicant shall receive a gaming license, the commission shall evaluate and issue a statement of findings of how each applicant proposes to advance the following objectives: (14) mitigating potential impacts on host and surrounding communities which might result from the development or operation of the gaming establishment; (19) gaining public support in the host and surrounding communities which may be demonstrated through public comment received by the commission or gaming applicant. Being a unique and new process, the dynamics of what level of traffic impact equates to qualifying for surrounding community status created a significant amount of consternation amongst each of the eight participating communities. This unease was compounded by the limited engagement of MGM in addressing these communities’ concerns pertaining to traffic

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impacts prior to the commencement of this regional traffic impact review process. As discussed below, the review process itself was conducted in an extremely compressed timeframe, which further increased the pressure on these communities to accept terms from MGM in order to guarantee their status as a surrounding community, prior to the obtaining a technical understanding of the actual traffic impacts to their respective communities as part of this review process. Review Timeline Similarly, the timeline for this review process is unique and therefore warrants discussion. The stated position of MGM was to have all surrounding community agreements in place prior to their December 31, 2013 Phase II application deadline. While there was some engagement with these communities prior to GPI’s involvement in the process, this engagement did not convey an effective understanding of impacts to these communities. It was not until the initial kick-off meeting for this review, held on November 14, 2013, that some information pertaining to traffic impacts on these communities was officially expressed by MGM/TEC. Consequently, this allowed for approximately one month for completion of this independent technical peer review for the communities, an aggressive timeline for a project of this magnitude. The objective of this review is to provide the communities in this process with an understanding of traffic-related impacts to call upon in engaging in potential discussions with MGM. At the initial kick-off meeting, GPI met with the MGM team and the eight communities selected to participate in this review process for the first time. Some traffic-related technical information was provided for GPI’s review at this meeting, however other relevant materials were found to be outstanding. It was not until November 27, 2013 that all necessary project materials were received. While GPI is confident that the MGM team participated in good faith (the materials where provided as prepared), it speaks to the further compression of the available time these communities had to prepare for the surrounding community process. GPI also met with representatives from each of the communities individually over four days between November 24th and December 4th to get an understanding of specific concerns and perspectives. On December 10th GPI re-engaged the communities participating in the process and conveyed our review findings. These findings are documented within this technical memorandum. GPI would also like to note the following as part of the review process:  There is limited information provided in the traffic study which identifies infrastructure costs in communities outside of the City of Springfield. Many communities expressed frustration that the infrastructure concerns they had previously expressed to MGM (prior to GPI’s involvement) where not incorporated into the TIAPS.

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The limited study area and timeline made it unfeasible to identify specific infrastructure costs at a number of locations as part of this review process as the timeline precluded the ability to collect necessary baseline data and conduct the necessary analyses. Further, these communities expressed frustration that no party had engaged them in conversations about impacts outside of traffic. Public safety, economic impacts and schools being the prevailing concerns. Prior to GPI’s involvement in the peer review process, representatives from MGM indicated a study on socioeconomic impacts was being prepared and would be shared with each of the eight potentially impacted communities. As the time of this submission, this has not happened and thus remains a significant concern to the subject communities. Concerns related to non-baseline traffic conditions were also expressed. These include concerns regarding additional traffic related to special events, traffic seeking alternate routes due to incidents on I-91, traffic impacts when combined with seasonal events such as the Eastern States Exposition (Big E) or ski resort traffic on I-91. These qualitative concerns fall outside of the norm of the analysis of a typical traffic study, but given the unique magnitude of the development project, should be weighed when determining impacts. Specific concerns related to infrastructure and uses within individual communities were identified, for instance the unknowns about the specific cross-promotional agreements between MGM and Six Flags New England in Agawam 3 or the potential re-introduction of passenger flights to Westover Air Force Base in Chicopee. Communities noted concerns related to significant increases in off-peak traffic. The peak traffic generation period of the Project is actually later in the evening on Fridays and Saturdays. The relative increase in delay and volume experienced during these periods is not a factor in the traffic study and is unaddressed. Communities immediately expressed concerns regarding the “look-back” methodology proposed by MGM to quantify impacts within these communities. The Look-Back Method is a proposal by MGM to compare existing and future conditions within a given community to determine the dollar value of any significant and adverse impacts a community has experienced from the Project. To accomplish this MGM would fund studies of community conditions by an independent party to be determined. These conditions would include net loss of commercial/retail activity, traffic impacts, utility impacts, public safety, real estate values and public education. The studies would consist

3 http://www.masslive.com/news/index.ssf/2013/11/mgm_springfield_partners_with.html

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of an existing baseline conditions study and subsequently a 1 year and 5 year look-back study. The look-back studies would be compared to the baseline study by the independent party who would issue findings concerning impacts. All parties would then work in good faith to mutually agree upon the dollar value of net significant and adverse impacts on the community. If the parties cannot agree on a dollar value an arbitration process would commence. Community concerns regarding the methodology of look-back and the ability to engage MGM in good faith subsequent to the MassGaming Commission process appeared universal amongst all communities. This topic is discussed in detail in this memorandum.

Trip Generation In determining if the traffic projections TEC utilized in the TIAPS are appropriate, GPI conducted a sensitivity analysis of both the Trip Generation and Trip Distribution methodologies. This sensitivity analysis was utilized to determine if any locations are potentially underrepresented in terms of potential traffic impacts. As a destination resort-style casino, MGM Springfield will be a significant generator of new traffic to the area. According to the traffic study prepared by TEC, on a daily basis4 it is estimated that the Project will generate 19,673 new vehicle trips (10,178 entering and 9,495 exiting vehicles). On a peak hour basis the Project is estimated to generate 1,290 new vehicle trips on a typical Friday evening between 5:00-6:00 PM. It should be noted that Saturdays are actually the peak traffic day of the week for casino developments, with a peak generating hour of 10:00-11:00 PM, however the worse-case combination traffic hour of local roadway plus Project trips is actually 5:00-6:00 PM on Fridays. The majority of our review focuses on this Friday evening peak hour, while still considering that this hour is actually not the peak hour of the generator throughout the course of the week. Typically, trip generation estimations are made utilizing data provided within the Trip Generation Manual published by the Institute of Transportation Engineers (ITE). In the case of casinos however, the trip generation manual does not contain data relevant to a development of this type. The numbers presented within the submitted traffic study are based on a hybrid methodology which employs empirical trip generation rates for the gaming/casino portion of the Project with traditional ITE trip generation rates for the remaining proposed ancillary land uses (Armory Square). The overall methodology employed by TEC is considered reasonable and

4 Daily and evening peak hour traffic volumes represent a typical Friday, historically the busiest weekday for casinos.

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appropriate for the trip generation analysis. Specific comments on the various aspects of these analyses are discussed in detail below. Gaming Trip Generation For the casino portion of the site the traffic study made use of empirical trip generation data collected at MGM’s gaming facility in Detroit, Michigan. Traffic counts collected at this facility were used to establish trip generation rates for the gaming portion of MGM Springfield. It should be noted that the gaming portion of this Project refers to all traffic related to patron and employee activity of the casino and the casino hotel. The resulting rates were compared to other casino projects within New England and nationally, and asserted by TEC to be higher than average and thus appropriate. It is important to note than when dealing with empirical data of this type the resulting methodologies are left to engineering discretion. Typically methodologies, such as those contained within the ITE Trip Generation Manual, are statistically analyzed and vetted through a scientific process. Empirical data is not subject to the same scrutiny, but rather used to provide a best estimate given the limited resources. For this reason the use of empirical data should be carefully understood and critiqued if appropriate. In this instance the use of empirical data from MGM Grand Detroit, while pertinent, does not control for all relevant factors. Based on traffic counts conducted at MGM Grand Detroit, a trip generation rate of 0.23 and 0.25 trips per gaming position was utilized to estimate the traffic generated from the casino portion of MGM Springfield during the Friday and Saturday peak traffic hours, respectively5. While MGM Grand Detroit is located in the downtown area, the demographics of Detroit are considerably different than those of the greater Springfield area. Detroit is the 11th largest metropolitan area in the nation, while Springfield is the 65th. Detroit is six times larger by population, 3.8 times larger by land area and 1.5 times as dense. Most importantly though is that MGM Grand Detroit is located within 1.5 miles of three other major resort-style casino developments, as shown on Figure 2. The effect of these competing uses is unknown, but it is reasonable to speculate that they potentially dilute the overall trip generation rate per gaming position of MGM Grand Detroit, which may be higher without this competition factor. Given this concern GPI would assert that, at a minimum, the rate per gaming position utilized to establish Project trips related to the gaming portion of MGM Springfield should be at least 20% higher than as presented in the TIAPS. Table 1 summarizes the changes to the gaming trip generation rate recommended by GPI, compared to the rate contained within the traffic study.

5 The 0.34 trips per gaming position mentioned previously is reflective of all land uses which comprise MGM Springfield; 0.23

and 0.25 reflects only the casino/hotel portion of the site.

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MotorCity Casino
3,300+ gaming positions 1,500+ seat theater 67,000 sf meeting space 400-room hotel 15 on-site restaurants/bars

Greektown Casino
2,800+ gaming positions 400-room hotel 10 on-site restaurants/bars

MGM Grand
4,890 gaming positions 30,000 sf meeting space 400-room hotel 11 on-site restaurants/bars

Caesars Windsor
3,800+ gaming positions 5,000 seat theater Convention space Shopping 750+-room hotel 11 on-site restaurants/bars

Figure 2 Detroit, Michigan Area Casinos

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Table 1 GAMING TRIP RATE COMPARISON
Time Period Friday: Evening Peak Hour (5-6PM) Peak of Generator (10-11PM) Saturday: Afternoon Peak Hour (2-3PM) Peak of Generator (10-11PM)
Note: a b

TEC Trip Rates a

GPI Trip Rates b

Delta

0.23 0.28

0.28 0.34

+0.05 +0.06

0.25 0.32

0.30 0.38

+0.05 +0.06

Trip rates represent the vehicular trips/gaming position associated with the gaming components of the proposed Project. These components include the casino patrons, casino employees and the hotel. Vehicular trip rate/hour utilized by TEC, Inc. in the DEIR submission - based on MGM Detroit counts conducted in July 2013. Adjusted vehicular trip rate/hour

Table 2 provides the same comparison but in actual vehicular trips related to the gaming portion of the Project. Table 2 GAMING TRIP GENERATION COMPARISON
Time Period Friday: Evening Peak Hour (5-6PM) Peak of Generator (10-11PM) Saturday: Afternoon Peak Hour (2-3PM) Peak of Generator (10-11PM)
Note: a b

TEC Vehicular Trips a

GPI Vehicular Trips b

Delta

879 1,078

1,055 1,294

+176 +216

945 1,223

1,134 1,467

+189 +244

Trips represent the vehicular trips/gaming position associated with the gaming components of the proposed Project. These components include the casino patrons, casino employees and the hotel. Vehicular trips utilized by TEC, Inc. in the DEIR submission - based on MGM Detroit counts conducted in July 2013. Adjusted vehicular trips/hour

As shown in Table 2, based on GPI’s adjustments an additional 176 trips could be expected to be generated during the Friday peak traffic hour throughout the study area.

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Armory Square Trip Generation The remaining ancillary uses proposed as part of the Project form what the proponent refers to as Armory Square. These uses comprise of a 250-room hotel, 52 apartment units, 4,000 sf daycare facility, 15-lane/22,000 sf bowling alley, 12-screen/1,000-seat multiplex cinema, 15,000 sf general office/radio station office, 35,000 sf of restaurants and 43,000 sf of various retail spaces. In totality, these uses combine to form a significant trip generation component to the Project. GPI has reviewed the trip generation projections associated with these uses and finds it to be acceptable and appropriate. Overall MGM Springfield Trip Generation Accounting for all proposed land uses, the trip generation rate employed for MGM Springfield is equivalent to 0.34 trips per gaming position during both the Friday evening commuting peak hour (5:00-6:00 PM) and the Saturday afternoon peak hour (2:00-3:00 PM). In the reviewer’s opinion the most logical benchmark for comparison are the existing gaming facilities in southern Connecticut. While the experiences of casinos nationwide are relevant, the most relevant is the trip generation characteristics of facilities which share the same consumer base and are regionally proximate. Based on conversations with the Connecticut Department of Transportation a rate of 0.34 trips per gaming position is typically employed for planning purposes when estimating casino trips. This rate is based on experiences at Foxwoods Resort Casino in Ledyard, Connecticut and Mohegan Sun in Montville, Connecticut. Further, based on information provided by TEC the rate for Mohegan Sun in Connecticut is as high as 0.38 trips per gaming position. It is TEC’s assertion that: The Mohegan Sun Resort casino experienced trip rates higher than the MGM Grand Detroit, which were also on the upper end of the trip rate range. The casino, along with Foxwoods Casino, is located in a more rural/suburban location than the MGM Grand Detroit and the proposed MGM Springfield. In addition, these casinos do not have access to public transportation, which may be the cause for the higher trip rates. GPI cannot concur with this assertion without further supporting evidence. While the MGM Springfield casino will have access to public transportation, it remains speculative to assume public transportation options are of sufficient convenience to sway a measurable amount of patrons/employees to switch to alternate modes of transportation; effectively lowering the vehicular trip generation rate as implied. Residents of the greater Springfield area regularly

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drive to these Connecticut casinos today and are likely to drive to the MGM Springfield casino as an alternative once opened. Furthermore, as a suburban/rural casino GPI would contend that this would make it less likely for trips to be made to the Connecticut facilities simply for the ancillary uses. For instance if one of these casinos where to contain a multiplex cinema as the proposed MGM Springfield does, it would appear less likely for a patron to drive to the remote Connecticut casinos to simply see a movie. In other words, patrons may drive to the casinos in Connecticut to gamble and take advantage of the ancillary uses, but are likely not driving that distance regularly for the ancillary uses alone. Contrast that with the proposed MGM Springfield development. Given its proximity to the surrounding urban/suburban developments in the greater Springfield area, it appears far more likely that a cinema customer may drive to downtown Springfield to see a movie at the new facility without participating in any gaming activity. For this reason GPI would assert that the overall trip rate per gaming position would be expected to be higher for MGM Springfield per gaming position than at the Connecticut casinos. This gives further rationalization to increase in the trip generation rates associated with the gaming portion of the development as previously described. Overall the trip generation rates asserted in the TIAPS appear reasonable given the unique nature of the facilities; however GPI does have concerns that the trip generation associated with the gaming portion of the site may be underrepresented. While GPI has critiqued the gaming portion of the trip generation methodology, we do concur with the other elements of the trip generation methodology employed. It is also important to note that to be conservative the TIAPS did not take a pass-by credit for the retail uses. Pass-by trips are not new trips, but rather vehicles already on the roadway network that visit the site on impulse on their way to another destination. In addition, a conservative transit credit of 5% was employed for Armory Square uses, and was not applied to the casino portion of the Project traffic. GPI would like to note that while the 5% transit credit is acceptable for the employees, assurances should be given to ensure that these transit services will be available for employees who need them. If transit services are available for only one leg of an employee’s commute they are much less likely to utilize this service. It is understood that MGM has engaged the services of Nelson/Nygaard to study the potential impact of the Project on existing transit service provided by the Pioneer Valley Transit Authority (PVTA). GPI is also aware that MGM has engaged in discussions with PVTA regarding the level of support that could potentially be provided to enhance public transit operations. Table 3 provides a comparison of the total trip generation of the proposed destination resort casino based on both TEC and GPI’s assertions.

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Table 3 TOTAL TRIP GENERATION COMPARISON
Time Period Friday: Evening Peak Hour (5-6PM) Saturday: Afternoon Peak Hour (2-3PM) TEC Vehicular Trips GPI Vehicular Trips Delta

1,290

1,466

+176

1,312

1,501

+189

Note: Trips represent the vehicular trips/gaming position associated with all components of the proposed Project.

For comparison purposes Table 4 provides a comparison of the overall trip generation rate (reflective of all uses) for MGM Springfield compared to other casino, or casino developments in the area. Table 4 TOTAL VEHICULAR TRIP GENERATION RATECOMPARISON
Milford Foxwood s 0.30 Suffolk Downs Caesars 0.31 Palmer Mohegan Sun^ 0.53 Wynn Everett 0.44 MGM Springfield TEC 0.34 MGM Springfield GPI 0.38

Time Period Friday: Evening Peak Hour (5-6PM) Saturday: Afternoon Peak Hour (2-3PM)

ConnDOT 0.34

0.36

0.38

0.32

0.49

0.51

0.34

0.39

Note: These rates account for vehicular trips/gaming position and do not account for additional person trips associated with transit. ^ Palmer proposal included significant ancillary uses (Water park, Cineplex (1,800 seats) and 250ksf retail)

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Trip Distribution In addition to trip generation, GPI reviewed the trip distribution methodology as it pertains to impacts on the surrounding communities. The many aspects of the various gravity models utilized to distribute projected traffic associated with the proposed land uses were reviewed in detail. For the casino gravity model, this included understanding the various components of the marketing study which were utilized to generate the gravity model. Journey to Work data which were used to generate the casino employee and office-related distribution model as well as assignment onto specific roadways were also assessed. MGM Casino Gravity Model MGM provided (for GPI’s review only), the proprietary marketing study which was used to determine the gravity model for the casino patrons draw. While the ability to critique the appropriateness of the factors that where contained within the model is beyond the scope of GPI as the traffic engineering consultant to conduct, GPI did foster an understanding of the model as it pertains to regional draw. Some of the factors contained within the marketing model downgraded the percentage of the local draw within the Pioneer Valley for various reasons. To reflect a level of conservatism in the sensitivity analysis for this review, GPI factored these local communities upwards a nominal amount to determine if, in the case of these assumptions proving to be false, the resulting impacts on the eight communities proved to be greater subject to this review process. Journey to Work The employee distribution is based on existing Journey to Work data contained within the US Census. These data represent where the existing workforce within the City of Springfield resides. While this is a typical approach for development projects with an office component, the existing percentage of employees employed in Springfield is quite heavily skewed to residents of Springfield (45%). Given the transformative nature and scale of the Project, it is reasonable, for sensitivity purposes, to consider that employment at the casino may be weighed more towards communities of residence outside of the City of Springfield. To account for this GPI weighed the employee draw away from the City of Springfield downward by a nominal amount and the draw from the eight surrounding communities upwards. Retail Gravity Model (Armory Square) GPI has reviewed the gravity model associated with the trip distribution projections associated with the ancillary retail uses within Armory Square and finds it to be acceptable and appropriate.

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Local Route Selection – Trip Assignment GPI considered the means by which vehicles were being routed through the local roadway networks within each individual community. This exercise resulted in the adjustment of the local distribution. GPI did not find any significant factors which grossly altered the local distribution percentages. The one exception pertains to traffic routed through the Town of West Springfield which appeared to disproportionately favor the North End Bridge over the Memorial Bridge. This will be discussed in more detail in the individual community impacts below. Figures 3 through 7 graphically present the results of the trip generation/distribution sensitivity analysis. The sensitivity analysis results in additional traffic projected into each of the eight communities as part of this review process. Figure 3 represents the percentage of overall traffic projected into each of the communities based on TEC’s ass ertions; Figure 4 represents these percentages based on GPI’s adjustments. Figure 5 presents Friday evening commuting peak hour vehicles entering into these communities based on TEC’s projections; Figure 6 presents these vehicles based on GPI’s adjustments. Figure 7 provides the delta of these Friday evening peak hour vehicle trips of GPI’s adjustments over TEC’s assertions.

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Source: TEC, Inc.

Figure 3 TEC Trip Distribution Map Friday Evening Peak Hour (5-6PM)

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Figure 4 GPI Adjusted Trip Distribution Map Friday Evening Peak Hour (5-6PM)

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Source: TEC, Inc.

Figure 5 TEC Projected Vehicle Trips Friday Evening Peak Hour (5-6PM)

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Figure 6 GPI Adjusted Vehicle Trips Friday Evening Peak Hour (5-6PM)

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Figure 7 Delta TEC vs. GPI Vehicle Trips Friday Evening Peak Hour (5-6PM)

REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

Traffic Impact Analyses GPI has reviewed the capacity analyses as provided in the TIAPS. While the study area contained within the TIAPS is limited in regard to its scope pertaining to the surrounding communities, the analyses that were provided were conducted in an appropriate manner. GPI reviewed the date of counts, seasonal adjustments, peak hour factors, roadway geometries, growth projections and the underlying interpretation of results amongst other factors. One minor note regarding the intersection capacity analyses. These analyses were conducted utilizing the 2000 Highway Capacity Manual (HCM) methodology. The latest 2010 HCM has been issued and represents the preferred methodology for conducting intersection capacity analyses. GPI is aware however of the technical challenges and feasibility in implementing this new methodology. GPI defers to MassDOT in determining the most appropriate means of conducting intersection capacity analyses. In addition, as discussed in detail in the community impact section, GPI recommends MGM prepare existing, no-build and build micro-simulation models of the I-91 corridor inclusive of all freeway elements included in the study area as well as the crossings of the Connecticut River and the rotaries on the west side of the river. These models are the only effective means to evaluate net impacts in a situation where individual highway elements are closely spaced and constrained capacity (diverge to the South End Bridge from I-91 for instance) results in downstream impacts to other highway elements. HCM analysis only views these elements in isolation and does not completely capture potential impacts of the system as a whole.

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REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

Revitalization Potential GPI would like to point out one additional caveat as it pertains to traffic impacts on abutting communities. The MGM Springfield casino proposal has been termed an urban casino. This is an appropriate classification, but one that may not completely capture the unique characteristics of this development proposal on the region. MGM Springfield is not just located in an urban context; it is reasonable to assert that it is to be located in the urban heart of greater Springfield and Pioneer Valley. Located just blocks from City Hall, it will be uniquely positioned to redefine downtown Springfield, more so than any other casino proposal considered in the Commonwealth. In fact this unique caveat of the project has been marketed as a factor in considering MGM Springfield: MGM Springfield is the only Western Massachusetts resort-casino project that provides the region with the opportunity of a lifetime to revive its urban core. Additionally, MGM Springfield will provide connectivity to existing amenities throughout the area, many of which are the leading attractions in the region. MGM Springfield celebrates Springfield as a "Gateway City" and with the millions of new visitors the project will draw to the area, we intend to return Springfield to the economic engine that it was once when Western Massachusetts flourished. Our unique urban design will encourage new tourism, culture and civic pride in Springfield and the region. MGM Springfield is simply the best choice to execute the turnaround this region has needed for many years.6 While this may be an incredible incentive to consider MGM Springfield, it should be noted that the traffic impacts considered in the TIAPS is limited to impacts associated with the specific casino development proposal. If however this Project has the intended effect of being the catalyst to the revitalization of downtown Springfield, the traffic impacts considered may only represent an incremental portion of the greater traffic picture. The quantity of unoccupied or underutilized building and land space in downtown Springfield that may be reoccupied (as a welcomed secondary effect of the project) is unknown. While this “revitalized” traffic potentially occurs by-right within the City of Springfield, it is still new traffic as it pertains to impacts on the surrounding communities. These communities could potentially see no positive economic impact from this revitalization, but bear an increased burden as a result of additional impacts to infrastructure this traffic entails. Given the magnitude of the potential regional impacts, GPI recommends that any surrounding community agreements be
6 http://www.mgmspringfield.com/faqs/faqs.aspx

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REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

developed through a prism of conservatism to account for the larger transformative potential this Project represents. Relying on the look-back method to be the sole means of determining mitigation to address impacts on surrounding communities, as proposed by MGM, does not afford an appropriate level of conservatism for all communities. Please see the concerns regarding the look-back method as detailed in the final section of this memorandum. Exclusively regarding traffic, GPI believes a “hybrid” method would be appropriate in some circumstances. This hybrid-method should be a combination of upfront dollars to address specific infrastructure needs in combination with the look-back method for locations where the needs are less certain. Community-Specific Traffic Impacts Through this technical review GPI has weighed the impacts of the proposed casino development on each of the eight communities selected to be part of this review process. It is apparent that not all communities are impacted equally. Where appropriate GPI has identified specific concerns which should be addressed prior to the opening of MGM Springfield to mitigate impacts on these communities. GPI has also noted in our discussions with these communities the distinction between infrastructure under local jurisdiction and that under Massachusetts Department of Transportation (MassDOT) jurisdiction. While GPI will certainly raise concerns related to state infrastructure as it pertains to relevant concerns of a community, it must be recognized that MassDOT is the ultimate decision maker regarding the needs of its infrastructure. Agawam – Agawam is impacted by Project traffic as a portion of regional traffic from the south and west will be channelized through Town to the South End Bridge (Route 57) or the MorganSullivan Bridge (Route 147) to and from the Project site. Based on GPI’s sensitivity analysis approximately 81 vehicle trips are expected to utilize roadways in Town during the Friday evening commuting peak hour. Agawam has signed a surrounding community agreement with MGM which contains the look-back provision for monitoring future mitigation needs. GPI has advised Agawam to monitor the Feeding Hills Center intersection (Springfield Street (Route 147)/Southwick Street (Route 57) at N/S Westfield Street (Route 187)), River Road at Main Street (Route 159), and the Main Street/Springfield Street intersections in addition to the South End Bridge rotary as the most likely locations to experience impact as a result of the casino proposal. The South End Bridge rotary is still the singular largest concern in Agawam as it pertains to Project traffic. This location is a top 200 high crash location, and one that has been a longstanding bottleneck for regional traffic. Recently MassDOT has upgraded the pavement markings at this location to include two circulating lanes around the rotary. This appears to have

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REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

improved regional traffic flows, although anecdotal observations by Town officials indicated crashes have increased at this location since this upgrade has been implemented. Long term improvements at this location remain in preliminary conceptual phases and appear to be tied to the larger long-term future of I-91 on the opposite side of the Connecticut River. MassDOT through the MEPA process should weigh-in to determine what, if any, role MGM should play in addressing this long standing regional concern. Chicopee – Project traffic impacts Chicopee most directly at the I-90/I-291 traffic signal. This location is under MassDOT jurisdiction and would ultimately fall to the state to determine the appropriate course of mitigation. Just to the north of this location however, is the traffic signal of Burnett Road at New Lombard Road. Traffic from this signal is known to back-up into the I90/I-291 intersection. Given the heavy trucking traffic which occurs along the Burnett Road corridor, this back-up is a concern. The ability to upgrade/coordinate traffic equipment at this location should be investigated. The intersection of Center Street (Route 116) at Hampden Street/West Street is also a location of concern which may be impacted by MGM traffic. This location is a HSIP eligible location as it appears in PVPC’s report on the Top 100 High Crash Intersections in the Pioneer Valley. GPI would suggest MGM facilitate a Road Safety Audit (RSA) through the Federal Highway Administration (FHWA) standard process at this location and commit to implementing any identified short-term improvements. Based on GPI’s sensitivity analysis approximately 226 vehicle trips are expected to utilize roadways within the City during the Friday evening commuting peak hour (albeit a significant amount will only use state infrastructure to access the Mass Pike). GPI has advised the City to also monitor locations along Memorial Drive (Route 33). The potential use of Westover Air Force Base for passenger air service has also been raised. MGM should convey any conversations they have had along these lines, if any, to the City. East Longmeadow – East Longmeadow is impacted by Project traffic in that a portion of regional traffic from the south and east will be channelized through Town on North Main Street (Route 83) and further onto Sumner Avenue in Springfield. Based on GPI’s sensitivity analysis approximately 88 new vehicle trips are expected to utilize roadways in Town during the Friday evening commuting peak hour. East Longmeadow has signed a surrounding community agreement with MGM which contains the look-back provision for monitoring future mitigation needs. GPI has advised East Longmeadow to monitor signalized locations along North Main Street (Route 83), and identified specific concerns related to this infrastructure, as the most likely locations to experience impact as a result of the casino proposal. Holyoke – While it does not share a common border with Springfield, Holyoke is impacted by casino traffic in that it consolidates regional traffic from the north and west through the City and directs them to I-91. Based on GPI’s sensitivity analysis approximately 81 new vehicle trips are expected to utilize roadways in City during the Friday evening commuting peak hour. The most

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Proposed MGM Springfield Development – Springfield, Massachusetts

specific needs lay along the one-way pair of Hampden Street/Dwight Street (Route 141) corridors which are expected to accommodate traffic from South Hadley to I-91. GPI recommends that MGM facilitate a Road Safety Audit (RSA) through the Federal Highway Administration (FHWA) standard process of the Dwight Street and Hampden Street intersections with Pleasant Street and fund any short-term recommendations which result. Additionally, the residential cut-through street of School Street should be monitored in the look-back process to ensure this cut-through issue is not exacerbated by the Project. GPI has also advised Holyoke to monitor a number of locations in proximity to I-91 exits 15 – 17 as locations most likely to be impacted by the proposed casino. It is the understanding of GPI that MGM is no longer engaging the City of Holyoke in the surrounding community process. Given its involvement in this process and that Holyoke is clearly more impacted by traffic than some communities which have signed surrounding community agreements, GPI is compelled to stress that Holyoke should be engaged in a manner similar to the other seven communities that were part of this review process. Longmeadow –Longmeadow is impacted by Project traffic in two primary ways, traffic traveling directly to and from the Project site along Longmeadow Street (Route 5) and the impact to traffic along Route 5 that is incurred as the result of additional delay on I-91 as a result of Project traffic. Based on GPI’s sensitivity analysis approximately 53 new vehicle trips are expected to utilize local roadways in Town during the Friday evening commuting peak hour. In addition however, Longmeadow is uniquely impacted by longstanding bottlenecks along I-91 around the Longmeadow Curve (the interchange of Route 5/I-91). MGM is projected to generate an additional 286 peak hour vehicle trips along this stretch of highway during the Friday evening commuting hour, an already congested period. GPI recommends that Longmeadow consult with MassDOT regarding these concerns. At a minimum MGM should prepare a detailed traffic simulation model (utilizing a program like VISSIM) to demonstrate the additional impact MGM traffic has on the longstanding regional bottlenecks in this area. The capacity analysis provided in the TIAPS is insufficient to understand the interaction various closely spaced highway elements have on one another. Highway Capacity Software (HCS+) analysis considers these elements in isolation, however clearly these elements impact one another quite regularly in a manner only simulation modeling can quantify. GPI recommends that this model include the entire I-91 corridor within the study area as well as both sides of the North End, Memorial and South End bridges. GPI has further advised Longmeadow to seek funds to upgrade signal equipment at the Longmeadow Street (Route 5) at Converse Street, Longmeadow Street (Route 5) at Forest Glen Road and Converse Street at Laurel Street intersections. In addition, monitoring was recommended for signalized locations along Longmeadow Street (Route 5), Shaker Road and Dwight Road as the most likely locations to experience impact as a result of the casino proposal.

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REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

Ludlow –Based on GPI’s sensitivity analysis approximately 16 new vehicle trips are expected to utilize roadways in Town during the Friday evening commuting peak hour. Ludlow has signed a surrounding community agreement with MGM which contains the look-back provision for monitoring future mitigation needs. GPI has advised Ludlow to monitor locations along Center Street (Route 21) and West Street as the most likely locations to experience impact as a result of the casino proposal. West Springfield – Of all of the communities considered in this review process the Town of West Springfield is considered the most heavily impacted in relation to traffic. Based on GPI’s sensitivity analysis approximately 135 vehicle trips are expected to utilize roadways in Town during the Friday evening commuting peak hour. This is traffic from not only the Town of West Springfield but also communities to the west which utilize Westfield Street (Route 20) to access the City of Springfield. GPI believes that traffic routed through West Springfield in the TIAPS analysis does not accurately reflect local traffic patterns. The TIAPS assumed that traffic to the Project site will utilize the North End Bridge to either access Main Street in Springfield or I-91 to further access the Project site. In actuality, traffic through West Springfield is expected to utilize the Memorial Bridge, given the lesser congestion issues and the direct proximity this bridge provides to the Project site. Traffic could potentially utilize Union Street/Memorial Avenue in a much more significant manner than projected in the TIAPS. Under this scenario capacity concerns at Union Street and Memorial Avenue would need to be addressed. This adjustment does not encompass the full range of impacts. MGM Springfield is separated from West Springfield by only the Connecticut River. The Merrick section of West Springfield, an area that was hit especially hard by the recent tornado, lies on the other side of the Memorial Bridge from the Project site. It is expected that this will generate a pedestrian demand across the Memorial Bridge. There is also a large parking lot at the Century Center Plaza, and it is feasible that this may easily become an overflow parking location, or a location for charter busses to be stored. The seasonal effect of the Big E is also a concern. Further, the additional traffic identified as part of the larger revitalization of downtown Springfield would have the most significant impact along Memorial Avenue as this is a point of concentration for traffic destined to downtown Springfield. GPI has advised the Town of West Springfield to seek direct mitigation to address Memorial Avenue, which is in need of investment, from Union Street to the Memorial Bridge. In addition GPI has advised West Springfield to monitor other locations along Park Street, Elm Street and Memorial Avenue (Route 147). Wilbraham –Based on GPI’s sensitivity analysis approximately 36 new vehicle trips are expected to utilize roadways in Town during the Friday evening commuting peak hour. Wilbraham has also signed a surrounding community agreement with MGM which contains the look-back provision for monitoring future mitigation needs. GPI has advised Wilbraham to monitor locations along Springfield Street and Boston Road (Route 20) as the most likely locations to experience impact as a result of the casino proposal.

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Proposed MGM Springfield Development – Springfield, Massachusetts

One caveat with the Town of Wilbraham is the existing project currently on the 2015 Transportation Improvement Program for the Pioneer Valley (TIP) to reconstruct Boston Road (Route 20) from Pasco Road in Springfield to Stony Hill Road in Wilbraham. This project extends only ¼ mile into Wilbraham from the Springfield city line. It is the understanding of GPI that the City of Springfield may be completing this project as a City project and withdrawing all but the Wilbraham portion from the TIP. This would leave the ¼ mile segment of Boston Road previously part of this TIP project unfunded. Furthermore, the signalized intersection of Stony Hill Road with Boston Road is a top 200 high crash location in the state. As the most likely route to be impacted by Project traffic, GPI recommends that all stakeholders, Town of Wilbraham, City of Springfield, MGM and MassDOT coordinate to develop a means to ensure that Boston Road from the city line and including the Stony Hill Road at Boston Road intersection be addressed.

Look-Back Finally, GPI wants to note our concerns regarding the look-back methodology to mitigate impacts from the proposed casino Project. The look-back methodology was an element that MGM has suggested to mitigate true impacts resulting from the proposed casino after construction is complete. Theoretically this could be a valuable tool to ensure that real impacts, as they materialize, are addressed. In reality however a clear and concise methodology has not been proposed. These communities are being asked to trust that MGM will engage them in good faith at a later date well after the conclusion of the MassGaming Commission process. Given the number of variables which would have to be monitored it is easy to contemplate a scenario where MGM may attempt to dispute any real responsibility related to traffic impacts. Besides deferring any mitigation for at least one year after grand opening of the casino Project, the lookback methodology imposes a significant burden on the communities to determine impacts, rather than the applicant. These communities will not only need to monitor traffic conditions, but understand seasonal variation, keep close tabs on other development proposals and generally invest time and effort ensuring they are well prepared to justify mitigation requests. The scope of these studies has also not been defined, including such aspects as what time periods are under consideration, the independent party determining the rate at which regional traffic is growing or declining, and the role increases in crash frequency plays. An additional concern is the potential disincentive for local municipalities to fix their infrastructure in deference to potentially asserting MGM’s responsibility. There are a number of issues which raise concerns about the actual effectiveness of the look-back methodology, which at its core seems to defer a community’s ability to have the MassGaming Commission be the ultimate arbiter of necessary infrastructure mitigation. GPI views the look-back methodology to be a tool which should only be employed if there is genuine ambiguity about potential impacts at any given location. It is preferable to

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REGIONAL TRAFFIC IMPACT PEER REVEIW
Proposed MGM Springfield Development – Springfield, Massachusetts

address locations where infrastructure needs and impacts are likely with specific mitigation from the onset, whether those locations where included for study in the TIAPS or not. As part of their discussions with the eight affected communities, MGM has suggested the future involvement of the PVPC and GPI (or a similar consultant) to assist in the review and oversight of data collection required as part of the look-back methodology. In order to implement this approach, an agreement between MGM and the affected communities will be necessary as well as funding to support this work.

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